Legal Opinion
Katherine F. Miller v. Commissioner of Internal Revenue, Joseph M. Detota v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided February 13, 1964No. 115, 116, Dockets 28168, 28169PublishedCited by 15 opinions
1Opinion of the Court
WATERMAN, Circuit Judge.
Petitioners appeal from adverse decisions of the Tax Court entered in consolidated eases on December 7, 1962, upholding the Commissioner of Internal Revenue’s assertion of federal income tax deficiencies against them for the years 1957, 1958, and 1959. 39 T.C. 505. Jurisdiction to review these Tax Court decisions is conferred upon this court by Section 7482 of the Internal Revenue Code of 1954.
Petitioners argued before the Tax Court that the receipts upon which the alleged deficiencies had been based did not constitute income within the meaning of Section 61(a) of the…
2Cases cited10 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Helvering v. New York Trust Co.Supreme Court of the United States · 1934
- Sims v. United StatesSupreme Court of the United States · 1959
- Roberts v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1949
- Eva L. Gaugler, on Behalf of Herself and as Under the Last Will and Testament of Raymond C. Gaugler, Deceased v. United StatesCourt of Appeals for the Second Circuit · 1963
5 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Agrashell, Inc. v. Bernard Sirotta Co.Court of Appeals for the Second Circuit · 1965
- Comtel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Claudio Severi v. Seneca Coal & Iron CorporationCourt of Appeals for the Second Circuit · 1967
- Time, Inc. v. United StatesDistrict Court, S.D. New York · 1964
- Jane M. Fanning (Formerly Jane M. Husting) v. Joseph J. Conley, Jr., as District Director of Internal Revenue for the District of ConnecticutCourt of Appeals for the Second Circuit · 1966
10 more not listed; retrieve them via the Exa API.